Knapp v. Northwestern University

Nicholas Knapp (plaintiff) was highly recruited by a number of universities to play basketball. However, prior to the end of his senior year of high school, Knapp suffered sudden cardiac death, meaning that his heart stopped, during a pick-up basketball game. Although he was revived by paramedics, an internal cardioverter-defibrillator was subsequently implanted in Knapp’s abdomen to detect heart irregularities. If Knapp’s heart stopped the device was designed to restart it. On the day following Knapp’s cardiac episode, Northwestern University (Northwestern) (defendant) informed him and his family that it would honor its commitment for a scholarship for Knapp to play basketball. Seven weeks after his collapse, Knapp signed a letter of intent to attend Northwestern. The fall of Knapp’s freshman year at Northwestern, the basketball’s team head physician, Dr. Howard Sweeney, declared Knapp ineligible to play for the year based on a review of Knapp’s medical records and after consulting with several other physicians. After the end of that basketball season, Northwestern and the Big Ten Conference declared Knapp permanently medically ineligible to play basketball. Consequently, Knapp has never practiced with the basketball team nor played in a college game. Knapp’s scholarship continues as well as other benefits only provided to student-athletes, but he is not allowed to do anything with the basketball team other than observe. The day Dr. Sweeney declared Knapp ineligible, Knapp filed suit against Northwestern under § 504 of the Rehabilitation Act of 1973, seeking an injunction prohibiting the university from excluding him from its basketball team. The district court agreed and granted the injunction. Northwestern appealed.